OIG: Site visits will work with integrity agreements

The Office of Inspector General (OIG) is offering more information about how site visits will be conducted as part of its corporate integrity agreement (CIA) billing reviews.

In a new section on its web site, the OIG explains the purpose of the site visits, who is subject to them, how entities are selected for site visits, and who at OIG conducts them. The new information also details what kinds of activities typically occur during the site visits, who is present during employee interviews, and whether claims reviews are conducted during the visit. It points out that OIG does not perform unannounced site visits and that entities are given two weeks notice prior to the visits, which are scheduled to minimize disruption to business operations.

The site visit information is part of a larger explanation by the OIG about how CIAs work. The information is available on the Internet at www.oig.hhs.gov/cia/ciafaq1.htm. These are some highlights:

Purpose of the site visits: The primary purpose of a site visit is to verify the entity’s compliance with the terms of its OIG integrity agreement CIA and to provide the OIG with an opportunity to observe an entity’s compliance program in practice.

Who is subject to a site visit: Any provider, practitioner, or entity currently under a CIA or other integrity agreement with the OIG is potentially subject to a site visit. Additionally, the OIG occasionally conducts site visits to assess an entity’s compliance program during the course of settlement agreement and CIA negotiations. Entities previously visited include hospitals, physician offices, nursing facilities, laboratories, third-party billing companies, Medicare contractors, ambulance companies, durable medical equipment suppliers, and home health agencies.

How site visits are selected: Entities are chosen both at random and based on specific criteria developed by OIG. Factors considered by the OIG in determining whether to conduct a site visit include: issues raised in CIA annual reports, the reporting of deficiencies, comprehensiveness of the compliance program, size of operation, provider type, and degree of cooperation when reporting or responding to OIG requests for information.

Who conducts the site visits: The visits are conducted by attorneys and/or program analysts from the Office of Counsel to the Inspector General.

How long a visit lasts: The average site visit lasts between 1½ to two days. Occasionally, for large entities, site visits may last for three days or more.